PRELIMINARY STATEMENT
Mr. Hotz is a 21-year-old individual, who resides in New Jersey and who has not consented to the jurisdiction of this Court. Despite the fact that SCEA has filed this action and represented that this matter belongs in the Northern District of California, SCEA now attempts to engage in a jurisdictional fishing expedition as a means to utilize jurisdictional discovery to achieve other ends. Although the Court has limited discovery to jurisdictional issues, SCEA has demanded overly burdensome and expensive discovery from Plaintiffs that bears little, if any, relevance to the issues at hand.
The Defendant has shown good cause for the protective order sought herein, as the discovery SCEA seeks is harassing, irrelevant, burdensome, expensive, and intrusive. In addition, the confidential information sought to be protected could cause Defendant irreparable harm if mishandled or exposed.
Mr. Hotz is not seeking to withhold information from Plaintiff. Instead, Mr. Hotz seeks only to (1) protect the information he is willingly providing by directing that the copy of his hard drive be created as-is and unaltered, and (2) relieve the undue burden and expense of appearing in this forum for a deposition where Mr. Hotz will gladly offer the same information through written deposition. Mr. Hotzhas been extremely accommodating to SCEA’s demanding requests– being responsive to questions and inquiries at all hours of the day and night, providing his personal hard drive with commercial, confidential, and valuable information so that SCEA can determine that nothing pertaining to jurisdiction resides on such drive, turning over his Playstation Computer, and remaining accessible despite the fact that he is not in the forum.
Mr. Hotz files this Motion for a Protective Order to limit the issues at hand to the matters of jurisdiction, and to limit such discovery to less burdensome means. The protection Defendant seeks would prevent irreparable harm and undue burden on Defendant, while still granting SCEA the information it seeks to discover, without any burden.

Invasion of privacy into financial matters was Sony trying to grasp for straws and drag any businesses into the mix that might have supported him with money. Too bad they would find that people have been donating to his legal fund as well, which is completely legal as far as I am concerned. Sony is reaching for any means to get the case done in California because no judge or jury in NJ are going to support them even with bribes which no doubt Sony will attempt to do with the court system in California.

Invasion of privacy into financial matters was Sony trying to grasp for straws and drag any businesses into the mix that might have supported him with money. Too bad they would find that people have been donating to his legal fund as well, which is completely legal as far as I am concerned. Sony is reaching for any means to get the case done in California because no judge or jury in NJ are going to support them even with bribes which no doubt Sony will attempt to do with the court system in California.

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Or they're trying to delay him, and make his legal costs skyrocket, hoping to bankrupt him.